Anti-Bribery Policy

Introduction

This anti-bribery policy sets out the position of TRM Innovations Ltd on bribery, corruption, facilitation payments, gifts, hospitality, conflicts of interest and improper business conduct.

TRM Innovations Ltd is a Bexleyheath-based building company providing services that may include extensions, refurbishments, kitchens, bathrooms, garage conversions, garden rooms, loft conversions and general building work.

We are committed to conducting business honestly and responsibly. We do not tolerate bribery or corruption by employees, workers, subcontractors, suppliers, consultants, representatives or any other person acting on behalf of the company.

Purpose of This Policy

The purpose of this policy is to make clear that bribery and corruption are not acceptable in any part of our business.

This policy is intended to help prevent improper payments, dishonest conduct, unfair influence and any behaviour that could damage trust in the company.

It also helps anyone working with or for TRM Innovations Ltd understand what is expected when dealing with customers, suppliers, subcontractors, professional advisers, public officials and other third parties.

Scope of This Policy

This policy applies to TRM Innovations Ltd and to anyone acting on behalf of the company. This may include directors, employees, workers, subcontractors, suppliers, consultants, agents and other representatives.

It applies to all business activity, including quoting, procurement, project management, customer communication, supplier relationships, subcontractor arrangements, professional referrals and any other work connected to the company.

Anyone working with TRM Innovations Ltd is expected to act honestly, follow the law and avoid conduct that could be seen as bribery, corruption or improper influence.

What Is Bribery?

Bribery means offering, promising, giving, requesting, agreeing to receive or accepting something of value in order to improperly influence a decision, gain an unfair advantage or reward improper behaviour.

A bribe does not have to be cash. It may include gifts, excessive hospitality, discounts, favours, free services, commissions, donations, personal benefits, employment opportunities or anything else of value.

Bribery can happen directly or through another person. It can also involve a third party acting as a middle person to hide the improper payment or benefit.

Our Zero-Tolerance Position

TRM Innovations Ltd has a zero-tolerance approach to bribery and corruption.

No person acting for or on behalf of the company may offer, give, request or accept a bribe. No person may make an improper payment to win work, secure an advantage, influence a decision, speed up a process or reward another person for acting improperly.

We expect all business relationships to be based on fair dealing, reasonable pricing, clear communication and proper workmanship.

Gifts and Hospitality

Reasonable gifts and hospitality may be acceptable in some business situations, provided they are modest, occasional, proportionate and not intended to influence a decision improperly.

Gifts or hospitality should never be offered or accepted if they could create a sense of obligation, influence a quotation, affect supplier selection, distort professional judgement or appear improper.

Cash gifts, cash equivalents, secret payments, excessive hospitality or personal benefits linked to business decisions are not acceptable.

Examples of Acceptable Gifts or Hospitality

Low-value and reasonable hospitality may be acceptable where it is connected to normal business practice and does not create improper influence.

Examples may include modest refreshments during a meeting, a small seasonal gift of low value or ordinary business hospitality that is proportionate and transparent.

Even where a gift or hospitality seems minor, judgement should be used. If it could appear to influence a decision, it should not be offered or accepted.

Examples of Unacceptable Conduct

Unacceptable conduct may include offering cash to secure a contract, accepting a personal reward from a supplier, giving a hidden commission for a referral, offering expensive gifts before a decision is made or requesting a payment to favour one contractor over another.

It may also include making unofficial payments to speed up approvals, providing personal benefits to influence project decisions or using a third party to make an improper payment on behalf of the company.

Any conduct that creates unfair influence or dishonest advantage is not acceptable.

Facilitation Payments

Facilitation payments are unofficial payments made to speed up or secure a routine action. These payments are not acceptable.

TRM Innovations Ltd does not permit facilitation payments, even where they are requested by another party or presented as normal practice.

If anyone is asked to make a facilitation payment, they should refuse and report the matter to the company as soon as reasonably possible.

Kickbacks and Secret Commissions

Kickbacks and secret commissions are not permitted.

A kickback may involve returning part of a payment as a reward for securing work or giving someone an unfair advantage. A secret commission may involve receiving a hidden payment for recommending a supplier, contractor, service or product.

All supplier, contractor and customer arrangements should be transparent and based on legitimate business reasons.

Political and Charitable Donations

TRM Innovations Ltd does not make political donations for the purpose of gaining business advantage.

Charitable donations must not be used as a way to influence a business decision, secure a project, obtain preferential treatment or disguise a bribe.

Any donation connected to the business should be transparent, lawful and made for a proper purpose.

Conflicts of Interest

A conflict of interest can happen when personal interests, relationships or outside activities could influence business decisions.

Anyone working for or with TRM Innovations Ltd should avoid conflicts of interest where possible and should disclose any potential conflict as soon as it becomes known.

Examples may include recommending a supplier because of a personal relationship, awarding work to a connected person without transparency or making decisions that create personal financial benefit.

Suppliers, Subcontractors and Third Parties

TRM Innovations Ltd expects suppliers, subcontractors and third parties to act honestly and responsibly.

We will not knowingly work with anyone involved in bribery, corruption, dishonest trading or improper business conduct.

Where appropriate, we may review supplier or subcontractor relationships if concerns are raised about improper payments, dishonest behaviour or unethical conduct.

Customer Relationships

Customers should be treated fairly and honestly. Quotes, project details and recommendations should be based on the work required, the condition of the property and the agreed scope.

No customer should be offered an improper benefit in exchange for misleading statements, unfair recommendations or dishonest advantage.

Likewise, no employee, subcontractor or representative should accept an improper benefit from a customer in return for preferential treatment or unauthorised changes.

Record Keeping

Accurate records help reduce the risk of bribery and corruption.

TRM Innovations Ltd aims to keep appropriate records of quotes, invoices, payments, supplier arrangements, project details and business communication.

False, misleading, incomplete or hidden records must not be created to conceal improper payments, gifts, commissions or business arrangements.

Reporting Concerns

Anyone who suspects bribery, corruption or improper business conduct should report the concern as soon as possible.

Concerns may relate to a payment request, unusual gift, supplier arrangement, customer request, subcontractor behaviour, false invoice, secret commission, conflict of interest or any conduct that appears dishonest.

Reports should be made to the company using the contact details shown on this page.

Protection for Raising Concerns

TRM Innovations Ltd does not want anyone to ignore a genuine concern because they are worried about raising it.

Anyone who raises a concern honestly and in good faith should not be treated unfairly for doing so.

Malicious or knowingly false allegations may be treated differently, but genuine concerns should be reported and reviewed properly.

Consequences of Breaching This Policy

A breach of this policy may be taken seriously and may lead to appropriate action.

Depending on the circumstances, this may include ending a working relationship, removing a supplier or subcontractor, reporting the matter to relevant authorities or taking legal action.

Bribery and corruption can also result in criminal offences, financial penalties and serious reputational damage.

Training and Awareness

TRM Innovations Ltd aims to maintain awareness of anti-bribery responsibilities and the importance of honest business conduct.

People acting for or on behalf of the company should understand that bribery, corruption, kickbacks and improper payments are not acceptable.

Where necessary, guidance should be sought before accepting gifts, agreeing unusual payment arrangements or entering into a business relationship that may create a concern.

Review of This Policy

This anti-bribery policy may be reviewed and updated from time to time to reflect changes in the business, legal requirements or working practices.

Any updates will be published on this page.

Contact Details

If you have any questions about this anti-bribery policy or wish to raise a concern, you can contact TRM Innovations Ltd using the contact details shown on this page.

This anti-bribery policy was last updated in June 2026.